Giancoulas v. Aetna Life Insurance Company of Canada

Giancoulas v. Aetna Life Insurance Company of Canada

The motions judge erred by ordering dismissal without sufficiently applying the principle that dismissal is a last resort and without being satisfied that giving the appellant one further opportunity to complete the defence medical examinations would cause non-compensable prejudice; accordingly the Court allowed the...

Source-derived case information.

Citation
C36655
Parties
Appellant: Ted Giancoulas; Respondent: Aetna Life Insurance Company of Canada
Court
Court of Appeal for Ontario
Jurisdiction
Canada
Judgment Date
1 May 2002
Procedural Posture
Civil Appeal / Appeal From Motions Judge Order Dismissing Action for Failure to Attend Defence Medical Examinations
Outcome
Appeal allowed in part; order dismissing action set aside and conditional compliance ordered
Legal Topics
Dismissal for Non Compliance, Defence Medical Examination, Sanctions, Costs
Source Language
en
Civil Procedure Insurance Law Dismissal for Non Compliance Defence Medical Examination Sanctions Costs

Source-derived case record

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Parties

Ted Giancoulas

Appellant

Aetna Life Insurance Company of Canada

Respondent

Procedural Posture

Civil Appeal / Appeal From Motions Judge Order Dismissing Action for Failure to Attend Defence Medical Examinations

  1. 1 Whether dismissal of the action for failure to complete court-ordered defence medical examinations was appropriate
  2. 2 Whether the motions judge applied the principle that dismissal is a measure of last resort
  3. 3 Whether further opportunity to comply would cause non-compensable prejudice

Ratio Decidendi

The motions judge erred by ordering dismissal without sufficiently applying the principle that dismissal is a last resort and without being satisfied that giving the appellant one further opportunity to complete the defence medical examinations would cause non-compensable prejudice; accordingly the Court allowed the appeal in part, set aside the dismissal and imposed conditional orders requiring payment for the missed appointment and completion of the examinations on the first available date, failing which the respondent may move to dismiss the action.

Court Disposition

Appeal allowed in part; order dismissing action set aside and conditional compliance ordered

Orders

  • Order of Lack J. dated June 21, 2001 dismissing the action is set aside
  • Appellant shall forthwith pay respondent $1,287.50 on account of missed appointment at Work Able Centres Inc. on September 12, 2000